In the case of Union Naval Stores Company v. United States, 1915, the Supreme Court ruled on whether a corporation could be held criminally liable for an offense committed by its agent within the scope of his employment. The Union Naval Stores Company was charged with making false entries in records required to be kept under federal law regarding turpentine production and sales. The company argued that it should not be held responsible because it did not authorize or know about these actions taken by its employee. The Supreme Court upheld the conviction against the company, establishing a precedent that corporations can indeed be held crimically liable for offenses committed by their agents acting within their authority and scope of employment even if those acts were done without explicit authorization or knowledge from corporate management. This ruling reinforced corporate accountability under U.S law.

In the dissenting opinion for Union Naval Stores Company v. United States, it was argued that the Sherman Act did not apply to this case because there was no evidence of a monopoly or restraint of trade. The dissenting justices believed that the majority misinterpreted and overextended the scope of the Sherman Act by applying it to situations where competition still existed and no monopolistic practices were evident. They contended that just because a company is large and successful does not mean they are automatically in violation of antitrust laws; there must be clear proof of anti-competitive behavior which, according to them, was lacking in this case. Furthermore, they disagreed with how much weight was given to certain pieces of evidence while other potentially exculpatory information seemed disregarded or overlooked.